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STATE OF MINNESOTA 


DISTRICT COURT 


COUNTY OF HENNEPIN 


FOURTH JUDICIAL DISTRICT 


IVlCllaad. DCtK, Odldll DCtK, ^IlCllUd. JDlUlll, 

Reginald Holmes, and Alexenderia Romig- 
Palodichuk, on behalf of themselves 
individually, and all others similarly 
situated, 


t^UUll rue 


Plaintiffs, 

v. 




Globe University, Inc., and Minnesota 
School of Business, Inc., 




Defendants. 





EXHIBIT C 



STATE OF MINNESOTA 



COUNTY OF WASHINGTON 



Heidi Weber, 



Plaintiff, 



v. 



Minnesota School of Business, Inc. d/b/a 
Globe University, 



Defendant. 



DISTRICT COURT 



TENTH JUDICIAL DISTRICT 



Court File No.: 82-CV- 12-2797 
Case Type: 7 - Employment 



AFFIDAVIT OF 
HANNAH VON BANK 



I, Hannah Von Bank, being first duly sworn upon oath, deposes and states as follows: 

1. My name is Hannah Von Bank. I am over twenty-one years of age. This 
Affidavit is based upon my personal knowledge and all of the facts recited herein are true and 
correct. 

2. I was an admissions counselor at Defendant from May 2012 to July 2012 at its 
Lakeville campus. 

3. During the course of my employment, I noticed that many powerpoint slides for 
each program presented ranges of salaries, which were presented to prospective students. All of 
the programs had either a range or a baseline starting salary like "$50,000 and up," for example. 

4. I can specifically recall the slide for the two-year associates degree in the 
Business Program. That slide, which was presented to prospective students, had a starting salary 
range of $20,000.00 - $60,000.00 per year for graduates of Defendant. 

5. The first three weeks of my job were dedicated admissions training. I, along with 
other admissions representatives, were trained by Charlie Potter, Primary Trainer at Globe 
University Corporate. 



6. When Potter discussed how to present the starting salary numbers to prospective 
students, he told us to say that "most people fall in the middle." Before I ended my employment, 
I determined this statement and many of the ranges presented to prospective students were 
fraudulent and misleading because they were not averages. I discovered that $60,000.00 was an 
outlier amount and that most graduates made closer to $20,000.00 - nowhere near the middle. 
Again, Potter instructed all admissions counselors to represent this range as an average. He told 
us that it was part of his "tips and tricks." His statement was not a part of the actual binder 
presented to admissions trainees. 

7. During admissions training, Potter instructed us to target veterans and their 
families because they fell under the GI bill and had "money at the ready for school." Potter also 
instructed us to target low-income persons. He gave the example of the single mom. Potter 
wanted trainees to target this demographic because those persons were eligible for pell grants 
from the Government, so it was like "free money" for Defendant. Later, Brian Saintey, Director 
of Admissions - Lakeville, and Ann Mickelson, Lakeville Campus Director, informed me that 
this was a general corporate practice. 

8. Also during admissions training, Potter instructed admissions trainees to sign up 
prospective students for financial aid as quickly as possible so the prospective would not have 
time to think it over. 

9. I was instructed by Roger Kuhl, Trainer, and Saintey to repeatedly call and 
"hound" family members of prospective students and say things like, you know Sally would 
have a great future in business and would make lots of money if she just got an education first 
and enrolled at Defendant, so have Sally call us back as quickly as possible. Saintey said this 
was a general coiporate practice that needed to be followed. 

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10. During my employment, I had extremely intense metrics to make my "sales" 
quotas when enrolling students. Saintey advised me that if I did not make my numbers, I would 
be fired. In addition, I had intense counseling sessions every two weeks with my superiors in 
order to make those numbers. 

1 1 . Potter instructed the admissions trainees to use "persuasive psychology" to 
"close" and enroll prospective students. Defendant's trainers used a technique where they made 
the school seem exclusive in order to get them to enroll. For example, I would present 
prospective students with a questionnaire. In one of the questions I asked, "what would you do 
with all the money you'd make in your new career?" The prospective student would answer 
something like well I'd get a nice house with hardwood floors and a big backyard, or similar. 
Then I would ask "well how are you going to make the money to get all that without an 
education? That's probably not possible." And usually, the prospective student would agree. 

12. In late July 2012, 1 voluntarily quit my job at Defendant because I believed 
Defendant's practices were fraudulent, misleading, and unethical. 



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FURTHER YOUR AFFIANT SAYETH NAUGHT 




Hannah Von Bank 



Subscribed and sworn to before me 
this /I "day of July, 2013. 




Notary Public 
My commission expires 




MARK J. MAKOWSKI 
NOTARY PUBLIC 
MINNESOTA 

My Commission Expires Jan. 3), 5015 



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